Where’s the Proof? NSF OIG Provides Insights on Crafting That All-Important Investigation Report

Health Care Compliance Association (HCCA)

Health Care Compliance Association (HCCA)

Report on Research Compliance Volume 20, no. 10 (October, 2023)

Please don’t send uncorrected transcripts of interviews conducted via Zoom or other means to the National Science Foundation (NSF) Office of Inspector General (OIG). Engaging in a “document dump” to OIG also doesn’t serve institutions or federal research misconduct investigators.

As research integrity officers (RIOs) know, making a finding of misconduct—defined as fabrication, falsification or plagiarism—is no small feat. First, there’s the inquiry phase, then, if warranted, a full investigation. Committee members must be impaneled, evidence gathered and protected, witnesses interviewed. The process should be handled with the utmost professionalism and well, integrity to ensure fairness and lack of bias.

And then there’s the report—a written accounting confirming or knocking down the allegations that are sent to the federal oversight agency. For HHS-funded investigators, that is the Office of Research Integrity. When the support comes from NSF, it’s OIG, specifically the Division of Research Integrity and Administrative Investigations in the Office of Investigations.

The tips on transcripts and the warning against a ton of unorganized information come from Valerie Hillgren, an investigative scientist in the division. In July, Hillgren—who joined OIG in 2016 after decades as a research scientist—gave a presentation on writing the report to a select audience of RIOs and others.[1] The meeting was not open to the news media, nor was it recorded. However, OIG posted slides from the workshop, and Hillgren agreed to an interview with RRC.

The first meeting of its kind, OIG planned the workshop to be an in-person event held in the summer of 2020—and then COVID-19 intervened. Three years later, OIG had the workshop but decided to keep it online to make attendance easier, Hillgren told RRC.

The purpose of the meeting was to “familiarize research integrity officers with our office and our procedures. We initially sent the invitation to the RIOs of all the institutions that had received over $1 million in funding from NSF in fiscal year 2022, as well as any RIOs from universities where we may have had cases. And then, we encouraged the RIOs to forward [the meeting information] to other interested parties. The Association of Research Integrity Officers helped us out by including our invitation in their newsletter,” Hillgren explained.

To choose workshop topics, “We brainstormed together and talked about, ‘What are some general things that we would like to get out there, what sort of information would we like to share with the RIOs?’ For us, an important thing is the report that we get back after an investigation because that’s the basis that we use to start our own independent assessment of the facts—the report that they write and the evidence that they give us,” she added.

Although her talk was titled “The Institution’s Investigation Report: Best and Worst Practices,” Hillgren said she spent more time on best practices—and report requirements. “We certainly did not want to appear as if we were trying to call out institutions for subpar reports,” she said. “We view our relationship with the RIOs as a collaborative enterprise. What we were hoping here is that by sharing with them what we need in a report, it would make both of our jobs easier.”

In her remarks and discussion with RRC, Hillgren focused on the final report that an institution develops at the end of an investigation. However, she also addressed the notification related to an inquiry that, in some instances, must be sent to OIG.

[View source.]

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